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I have been advocating for my special needs son in a special education impartial hearing. (In other words I am acting pro se.) I must now write a Closing Argument. I have a pretty good idea about what points I want to make, but I want to read one or more sample Closing Arguments, to get an idea of the tone, the format, how granular to make it, whether to just number the points, or to use more of a hierarchical outline (1, a, b, c, 2, a, b, c, etc.). That sort of thing.

The hearing officer said that the first section will be "Proposed Findings of Fact". He said the second section will be some legal analysis. What is that second section typically called? I mean, what title or heading should I give that section?

I have tried googling but I keep finding hearing decisions. That's interesting reading, but I really need to read a couple of Closing Arguments.

How do I find them?

I am especially interested in cases having to do with initial eligibility. The category Other Health Impaired if possible. High cognition students.

But I can still benefit from looking at some that don't have anything to do with my son's situation.

  • I don't know about special education hearings in particular, but I do know quite a bit about proposed findings of fact. That section is very important because you will outline exactly what you would like the judge or examiner to find. If the judge agrees with you, the judge will start by copying your proposed finding of fact as their findings of fact. Make sure that section has every fact in it that you would like the judge to find and that you have supported in other documents. It should be VERY granular so the judge can pick and choose which facts to bring from your document. – David Sep 27 '16 at 0:05
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    @David - Thank you. Now, do I group and outline, or do I just go 1, 2, 3, ... 279? Also, I really need to read a sample Closing Argument. How do I find one? – aparente001 Sep 27 '16 at 0:14
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    You should do both. Number consecutively but add subject headers. So you would do something like "Homework: 1. ..., 2. ..., Note Taking: 3. ..., 4. ...,". – David Sep 27 '16 at 18:18
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    @David - I wrote to the author of Do It Yourself Special Education Due Process: An Educational Guide, Dorene Philpot, and today she kindly sent me a sample closing argument, for educational purposes. She had done exactly what you described! If you make this an answer I can accept it. – aparente001 Sep 27 '16 at 20:01
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    The Do It Yourself book I mentioned is THE BEST resource for a parent wanting to go to due process pro se. If anyone comes across this -- buy it from her website, not from Amazon -- much cheaper. Her website doesn't make it clear, but it is actually a digital download. An affordable book and extremely helpful, and so inspiring. Dorene is amazing. – aparente001 Sep 27 '16 at 22:23
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The specific state you live in matters a lot so it is hard to say exactly. Often law schools or legal benefit organizations will have a law library that can help you. A library that has a how-to book specific to your state would be a good start. It sounds like the hearing examiner is friendly, so she might recommend a book or resource to help you organize. It is in her best interest to have your papers in order. Also, call an attorney who does this and see if they will recommend a book, (or as you did, email the author of such a book to get an example).

NOLO press offers a number of books for pro-se litigants that are generally a good place to start. They aren't treatises on the subjects, but also aren't just internet repeated wisdom and are often authored by practicing attorneys.

Good luck with your case.


Helpful info from comments made by this contributor:

You should do both. Number consecutively but add subject headers. So you would do something like "Homework: 1. ..., 2. ..., Note Taking: 3. ..., 4. ..., etc."

Make sure that section has every fact in it that you would like the judge to find and that you have supported in other documents. It should be VERY granular so the judge can pick and choose which facts to bring from your document.

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